ABOUT US - CORPORATE PROGRAMS

ENVIRONMENTAL POLICY STATEMENT

Lexington Home Loans is committed to environmental excellence and, as a matter of longstanding policy, recognizes the importance of protecting the global ecosystem reducing the use of natural resources and encouraging investment in ways that support responsible and sustainable development. This environmental policy is one part of the firm's core business principle of Responsible Citizenship.

The firm's environmental policy is intended to create long-term positive environmental benefits and conserve natural resources including minimizing energy and water consumption wherever possible. It also is intended to assure the protection of employees and all members of the global community.

Lexington Home Loans is a financial services firm and has administrative operations that result in minimal direct environmental impact. The firm, however, takes a proactive role in maintaining strict environmental management standards. Within its operations, the firm is measurably reducing the environmental impact by stressing reduction at the source.

Lexington Home Loans engages in waste minimization practices. Lexington Home Loans recycles or reuses natural resources and encourages employees to extend its recycle/reuse program to offices, cafeterias and community activities. The firm communicates to its employees the importance of pollution prevention through waste reduction, reuse and recycling, and encourages employee involvement in the environmental issues. The firm works with communities and municipalities to find new ways of reducing the environmental impact of our operations.

Lexington Home Loans operates in an environmentally sensitive fashion including having no emissions of greenhouse gases or ozone- depleting substances in its everyday operations. All buildings are managed with energy efficiency as a goal. The firm conducts ongoing monitoring and adheres to stringent environmental regulations, in addition to adopting best practices. Environmental assessments are conducted regularly outside consultants. The firm continuously sets important targets for energy and resource efficiency and conservation. Lexington Home Loans's current target is to reduce aggregate energy consumption at its major proprietary facilities by at least 2% on average over each of the next five years.

Lexington Home Loans and its charitable foundation contribute to environmental and global sustainability organizations. Employees volunteer contribute their resources to environmental programs. The firm participates in active discussions with environmental organizations and advocates and welcomes input as part of its public policy effort.

"Excellence & Integrity" underscore everything Lexington Home Loans does in its business activities. Employees are committed to observe the highest ethical standards and to exercise proper judgment in all aspects of business dealings. No individual bottom line is more important than the reputation of the company. Environmental impact is a reputational issue considered when the firm conducts its business activities.

ANTI-MONEY LAUDERING PROGRAM

Following the attacks on 11 September 2001, the U.S. government enacted the USA PARTIOT Act, which is designed to prevent the use of the U.S. financial system to help fund terrorism and other crimes. The Act, which is similar to regulations in other countries in which we do business, imposes a series of new anti-money-laundering requirements on brokerage firms and other financial institutions. Lexington Home Loans has had a vigorous money-laundering prevention program in place for years. In accordance with the Act, we have undertaken efforts to further enhance these existing policies and procedures.

We believe that compliance with the new regulations is of the utmost importance, and have dedicated significant resources to ensure that Lexington Home Loans helps set the standards for best practices in this area.

We have dedicated ourselves to enhancing our existing efforts in the fight against money laundering around the globe. As a firm with 200+ investors, we have been working closely with all our business partners to ensure that we comply with all anti-money-laundering efforts wherever we operate.
Our Program

Under the USA PATRIOT Act and other regulations, financial services firms must establish a compliance program, which includes policies and procedures to detect and report suspicious transactions to the government, as well as ensure compliance with the new laws. Firms must also implement specialized employee training programs, designate a special compliance officer and conduct independent audits of the effectiveness of the compliance program.

Lexington Home Loans has named an anti-money-laundering officer to lead our program and has appointed business and regional anti-money-laundering officers to support this effort. We are implementing an enterprise-wide suspicious activity reporting system that will enable us to better report suspicious activity to the government. All of our employees are being trained in anti-money-laundering practices and procedures, as well as the details of the firm's policies.

The regulations also impose new requirements regarding client information and verification of that information. Financial services firms are required to verify the identity of the clients with whom they do business, determine the source of funds in a client's account and obtain the information about a client's wealth.

At Lexington Home Loans, we have always stressed the importance of knowing our clients. This tradition has developed not only form regulatory requirements but also from the belief that the better we know our clients, the better we can serve their financial needs.

As part of our compliance with the new Act and in support of the fight against money laundering around the world, we may ask clients for additional information and documentation about certain accounts and transactions. This information may be used to verify client identity.

Lexington Home Loans has been a leader in anti-money-laundering efforts since the mid-2007s. With the advent of the USA PATRIOT Act and our enhanced compliance, Lexington Home Loans clients can take even greater comfort in doing business with us.